The CFPB’s current proposal to the court is inadequate.

As we noted on April Fool’s Day, the CFPB has proposed to the court a dramatic cut in the CFPB staffing. If only it were in fact an Apri Fool. American Banker’s Kate Berry has more here. Bloomberg’s Evan Weinberger has this paragraph in his story on the proposal:

The cuts may still be “draconian,” but the latest proposal “is almost the best result for the staff and the union that could be achieved under the circumstances,” said Mike Silver, a Spencer Fane partner and former CFPB regulatory attorney.

Despite Mr. Silver’s remarks, I don’t see how the Bureau can come close to meeting its statutory obligations under this proposal. Here’s one example: The proposal reduces the Office of Fair Lending and Equal Opportunity to four people. Dodd-Frank says that office is supposed to conduct oversight and enforcement of Federal fair lending laws, coordinate with other Federal agencies and the states, work with private industry and consumer advocates on compliance and education, and give Congress annual reports. Those four people are going to be busier than a two-armed paperhanger, much less a one-armed one, as the saying goes. And that’s without taking into account the administration’s debanking initiatives, which they may be charged with enforcing. That’s just one office. The proposal needs to explain how the Bureau will accomplish each of its statutory obligations with this staffing level. It doesn’t, almost certainly because it can’t.

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